Legal Opinion

Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Tenth Circuit

Decided January 21, 1976No. 74--1388PublishedCited by 90 opinions

1Opinion of the Court

HOLLOWAY, Circuit Judge.

This appeal challenges a determination made by the Commissioner of Internal Revenue that compensation paid to the executive officer of a closely held corporation was unreasonably high in three tax years, deductions for the full amount of the compensation should be denied, and that deficiencies existed. The Tax Court sustained the findings of unreasonableness of compensation, allowing however more deductions than the Commissioner. 61 T.C. 564.

The taxpayer is the Pepsi-Cola Bottling Co. of Salina, Inc., a Kansas corporation engaged in the manufacture, packaging and…

2Cases cited15 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  3. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  4. Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
  5. Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966

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3Cited by90 opinions

  1. Levenson & Klein, Inc. v. CommissionerUnited States Tax Court · 1977
  2. Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
  3. Kennedy v. CommissionerUnited States Tax Court · 1979
  4. Thomas v. CommissionerUnited States Tax Court · 1989
  5. Steel Constructors, Inc. v. CommissionerUnited States Tax Court · 1978

85 more not listed; retrieve them via the Exa API.

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